The United States Environmental Protection Agency (EPA), prior to the present invention, has required monitoring and reporting on individual sources of actual or potential undesirable emissions of gaseous matter or liquid matter. These requirements have heretofore been satisfied by “end of the line” monitoring techniques. Heretofore, there has been no known method or system for the environmental monitoring and reporting of a combination of gaseous and liquid emissions from a production facility.
Of recent, the EPA combined air and water regulation applying to the pulp and paper industry, known as the Cluster Rule. This Cluster Rule was developed to minimize and control Hazardous Air Pollutant (HAP) emissions via direct air vents from non-condensable type gas systems (NCG) (referred to in the Rule as Low Volume High Concentration (LVHC) and High Volume Low concentration (HVLC systems), and from volatilization fro HAP bearing liquid streams originating in the pulping and evaporation processes. These liquid streams are produced from the condensation of relief or evaporation vapors in various direct and indirect condensing systems in the aforementioned areas. The Cluster Rule refers to these HAP bearing condensates as “named streams”.
The Cluster Rule is unique in the history of the industry as It is the first Rule to require monitoring of significant process parameters in the mill proper, and the first Rule to require the daily/continuous inventory of HAP9 produced in the mill proper. Most regulations look at final emissions on end-of-pipe treatment systems and their respective treatment efficiencies (eq. wastewater treatment basins, steam strippers, recovery boiler electrostatic precipitators etc). The industry was faced for the first time with monitoring AND reporting in-process activity as relates to HAP evolution, in addition to treatment. Many of these process areas were never monitored to this extent in the past and in many cases, no instrumentation was even present to track required parameters. Many new condensate collections systems had to be built with new piping to transport condensates from evaporator and pulping condensers to a main collection tank prior to delivery to one or more treatment devices. Operation parameters in the evaporators such as liquor flow, liquor solids, conductivity, condensate flow, temperature and valve positions along the delivery piping (to confirm actual collection) had to be installed and connected to the mill distributed control system (DCS) and process information (PI) systems. Digester systems required monitoring of chip meter rotation as an Indicator of pulp production, conductivity, condensate flow, temperature and valve position. Many of the Cluster Rule requirements did not provide instruction on the development of the monitoring and tracking systems, only the final goals.
On Apr. 15, 1998 the Environmental Protection Agency (EPA) promulgated the Cluster Rule for the pulp and paper industry. These rules establish the effluent guidelines and standards under the Clean Water Act and the national emission standards for EPA's designated hazardous air pollutants under the Clean Air Act and have a mill-wide effect on the affected International Paper mills.
The Clean Air Act Amendments of 1990 designated certain substances as hazardous air pollutants (HAPs) and required the industry to reduce HAPs using Maximum Achievable Control Technology (MACT) control measures. MACT means the best demonstrated control technology or practices used by similar sources of air toxics, defined by law as the average pollutant reduction achieved by the best-performing 12 percent of mills. The MACT regulation for the pulp and paper mills is codified in 40 CFR Part 63 Subpart S.
The regulation requires pulp and paper mills to control HAPs, using methanol and chlorine as surrogates in the mills' condensate, LVHC/HVLC and bleach plant systems, respectively.